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having an original depreciable basis of $4,000." We do not
believe this provision is clear and unambiguous because it could
be read on its own to limit the type of cattle held by the
partnerships. However, we interpret this paragraph as qualifying
the one directly proceeding it which limits the number of cattle
subject to depreciation for each year, and neither party has
suggested a different interpretation. After considering these
provisions and the agreement as a whole, we reject petitioner's
argument that the provision limiting the number of depreciable
cattle should be read to limit the total number of cattle held by
the partnerships.
Even if we found the agreement ambiguous as to this
provision, petitioner has offered no extrinsic evidence that
supports petitioner's position. We find that the agreement
limits only the number of cattle subject to depreciation, but
does not limit the number of nondepreciable cattle owned by the
partnerships.
Petitioner further argues that the portion of the agreement
which provides that principal payments will begin in the sixth
year of the partnership should be enforced by including that such
payments are to be made by the transfer of registered shorthorn
heifers. The language of the agreement is silent as to the
method of payment.
Petitioner's proffered evidence, when considered in light of
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